[Ctn-crosscom] FW: [ccTLDcommunity] Questionnaire CCWG Use of names of country and Territories: 3-letter codes

Mon Nov 9 18:11:04 UTC 2015

Dear all, please find below responses form the .pl registry operator.
Very best. 
Lars

From:  Roman Malinowski <Roman.Malinowski at nask.pl>
Date:  Thursday, 5 November 2015 05:30
To:  Lars HOFFMANN <lars.hoffmann at icann.org>
Subject:  FW: [ccTLDcommunity] Questionnaire CCWG Use of names of country
and Territories: 3-letter codes

Dear Lars,

In refer to the set questions, please see my comments  below in this  note.
I think, that You should know, that my experience with ICANN and domain
industry is rather short one; just a couple of years.  The presented
comments have been formed mainly in refer to the messages presented on the
attached slides, however I should add that my understanding of ISO 3166 is
not only in context of domains.

Best regards,
Roman.   

Roman Malinowski
Head of DNS Department | NASK | www.nask.pl
mobile +48 692 158 947 | tel +48 22 380 85 06
ul. Wawozowa 18 | 02-796 Warsaw | Poland

From:cctldcommunity-bounces at cctld-managers.org
<mailto:cctldcommunity-bounces at cctld-managers.org>
[mailto:cctldcommunity-bounces at cctld-managers.org
<mailto:cctldcommunity-bounces at cctld-managers.org> ] On Behalf Of Bart
Boswinkel
Sent: Wednesday, November 04, 2015 10:31 AM
To: ccnso-members at icann.org <mailto:ccnso-members at icann.org> ;
cctldcommunity at cctld-managers.org <mailto:cctldcommunity at cctld-managers.org>
Cc: Lars Hoffmann; ccnso-council at icann.org <mailto:ccnso-council at icann.org>
Subject: [ccTLDcommunity] Questionnaire CCWG Use of names of country and
Territories: 3-letter codes

Dear all,
Please find included a request for input from the cross-community working
group  on the Use of Country and Territory Names as top-level domains
(CWG-UCTN). Please respond to lars.hoffmann at icann.org
<mailto:lars.hoffmann at icann.org>  (also included in the cc). Closing date is
30 November 2015. The questionnaire is a follow-up from the presentation
Annebeth Lange (.no) and Paul Szyndler (.au) gave at the ccNSO meeting in
Dublin. Their presentation can be found here:
https://meetings.icann.org/en/dublin54/schedule/tue-ccnso-members/presentati
on-ctn-20oct15-en.pdf
<https://meetings.icann.org/en/dublin54/schedule/tue-ccnso-members/presentat
ion-ctn-20oct15-en.pdf> .

Kind regards,
Bart Boswinkel

--------------------
Dear all,
As you may be aware, the ccNSO and GNSO Councils have chartered a Cross
Community Working Group on the Use of Country and Territory Names as
top-level domains (CWG-UCTN). The objective of the CWG-UCTN is to review the
current status of representations of country and territory names, as they
exist under current ICANN policies, guidelines and procedures. In addition,
the Group has been asked to provide advice regarding the feasibility of
developing a consistent and uniform set of definitions that could be
applicable across the respective SO's and AC's for country and territory
names as top-level domains. Please note that the scope of the WG is strictly
limited to:
·         Representations of names of Countries, Territories and their
subdivisions listed on or eligible to be listed on the Alpha-2 code
International Standard for country codes and codes for their subdivisions
(ISO 3166-1), (Names of Country and Territory). Other geographical
indicators, such as regions, are excluded;
·         The use of Country and Territory names as Top Level Domains. The
use of Country and Territory names as second or other level is excluded.

The CWG-UTCN has divided its work into three work stream: 2-letter codes,
3-letter codes, and full names of countries and territories; currently the
Group is starting its discussion on 3-letter codes and it is on this issue
specifically that your feedback is being sought at this time. Please note
that the community will be given ample opportunity to comment and provide
feedback on all other issues in due course.

To help the CWG-UCTN in its discussion on three-character codes, you will
find below a number of questions; it would be very helpful to the Group if
you could provide feedback on some or all questions raised. Please do not
hesitate to supply any additional comments you may have on three-letter
codes, as long as they are within the scope of work of the CWG (see above).

Please send your comments to Lars Hoffmann (lars.hoffmann at icann.org
<mailto:lars.hoffmann at icann.org> ), who is part of the CWG¹s staff support
team, by Monday 30 November 2015. If you cannot submit your input by that
date, but you would like to contribute, please let us know when we can
expect to receive your contribution so we can plan accordingly.

Your input will be very much appreciated.
 With best regards,

Heather Forrest, GNSO (Co-Chair)
Carlos Gutiérrez, GNSO (Co-Chair)
Annebeth Lange, ccNSO (Co-Chair)
Paul Szyndler, ccNSO (Co-Chair)

Questions by the CWG-UCTN on 3-character codes with regard to the use of
country and territory names as top-level domains

1.      In future, should all three-character top-level domains be reserved
as ccTLDs only and be ineligible for use as gTLDs? What would be the
advantage or disadvantage of such a policy?

No, they should not, however all 3-character names listed in ISO tables are
to be maintained in line with ISO rules and policy. This question is general
one and somewhat misleading;  my understanding of this project is that we
are not in position to break down the ISO eligibility rules and create our
own on Internet with regard the 3-character names.
2.      In future, should all three-character top-level domains be eligible
for use as gTLDs as long as they are not in conflict with the existing
alpha-3 codes from the ISO 3166-1 list; i.e. the three-character version of
the same ISO list that is the basis for current ccTLD allocation? What would
be the advantage or disadvantage of such a policy?

Yes, they should, however we have to have in mind that the 3  character
names listed in ISO tables ( not only limited to ISO 3166-1) relate to the
names of currencies, the names of languages, etc. The eligibility  should be
maintained in line with ISO established policy.  In general there is no need
to design  a policy which may limit Internet development.

3.      In future, should three-character strings be eligible for use as
gTLDs if they are not in conflict with existing alpha-3 codes form the ISO
3166-1 list and they have received documentation of support or non-objection
from the relevant government or public authority? What would be the
advantage or disadvantage of such a policy?

It would be reasonable to answer shortly by saying  yes, they should.  I
think, that would wise to keep in mind that many governments in fact are not
in position to predict the future of its states; please refer for instance
to the example of former Yugoslavia or Africa where we can see many new
countries  ³born² in Africa, etc. What would be the value of the mentioned
permission? For  how long will it be valid?  With that rule in mind, for
sure, someone in the future would  have to decide what is at higher value by
weighting an commercial interest vs. the interest of a new nation for
instance?  Do we really consider, that our legitimate is sufficient? and
could  prevail the one by UN? As already mentioned, the ³ delegation  (
free) for assignment by ISO² 3-character names shall be handled by ISO.  In
addition, we can see that, there are many 3 character names which most
probably will be never used by ISO; and I do believe that ISO knows that and
keeps the list. I think, that these 3-character names should be allowed in
naming of the top level domains.

4.      In future, should there be unrestricted use of three-character
strings as gTLDs if they are not conflicting with any applicable string
similarity rules? What would be the advantage or disadvantage of such a
policy?

In order to be consistent with the rules and policies we have already got  I
would vote for the unrestricted use, however the definition of the meaning
of ³ unrestricted² in this context has to be set first.   Having in mind the
understanding of intention presented above, I found this question  as
general one. 

5.      In future, should all IDN three-character strings be reserved
exclusively as ccTLDs and be ineligible as IDN gTLDs? What would be the
advantage or disadvantage of such a policy?

I do not think so, however there is some idea behind.  First of all we are
not sure about the future regarding IDN; it is complex technology which can
cause Internet less stable or even partially unstable. I think we need more
research and better analysis; otherwise, I think that  we do not have enough
knowledge to build any theoretical project and set the rules.  The question
is:  do we have to decide just now? What is a reason behind  for making a
decision even if it would be wrong in the future? ( as our today¹s knowledge
is not sufficient enough..?). In general, the rules applied should be as
presented above.  

6.      In future, should there be unrestricted use of IDN three-character
strings if they are not in conflict with existing TLDs or any applicable
string similarity rules? What would be the advantage or disadvantage of such
a policy?

As above, it would be good to have the unrestricted use, however the
definition of the meaning  of ³unrestricted² in this context has to be set
first. 

7.      Do you have any additional comments that may help the CWG-UCTN in
its discussion on three-character strings as top-level domains?

In general, we should do our best and avoid of creating the artificial
barriers driven by unjustified reasons and curb Internet development,
however I think that the planning process in projects should follow the set
polices and ISO rules first;  I do think, that we  have not got a legitimate
position to change the UN policy and maintain any new one. Doing
differently, I think that  simply sooner or later the projects will fail,
and the team will be busy with huge load  and unproductive work.  The known
rule first come first served in this context is note the one we should focus
on first.

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